20170815Wyoming_WIEC Set 1 (1-3).DOCX

BEFORE THE PUBLIC SERVICE COMMISSION OF WYOMING
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR CERTIFICATES OF PUBLIC CONVENIENCE AND NECESSITY AND NONTRADITIONAL RATEMAKING FOR WIND AND TRANSMISSION FACILITIES.
DOCKET NO. 20000-520-EA-17
(Record No. 14781)WYOMING INDUSTRIAL ENERGY CONSUMERS’
FIRST SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
The Wyoming Industrial Energy Consumers (“WIEC”), an unincorporated association comprised of industrial energy consumers, by and through its undersigned counsel, Holland & Hart LLP,respectfully submits its first set ofdata requests to Rocky Mountain Power, a division of PacifiCorp (“Company” or “Rocky Mountain Power”). The following response date, definitions, and instructions apply to this set of data requests:
RESPONSE DATEPlease respond to these data requests within 30 calendar days, i.e., by August 16, 2017, unless an earlier date is specified by the Wyoming Public Service Commission or by agreement between WIEC and Rocky Mountain Power.
DEFINITIONS
“Applicant,” “RMP,” “Rocky Mountain Power,” “Company,” or “you” means Rocky Mountain Power; any merged or consolidated predecessor or predecessors in interest; parent(s), subsidiaries and affiliates, past and present; and the employees, officers, directors, agents, consultants, attorneys and all persons acting under contractual arrangement with or acting or purporting to act on behalf of Rocky Mountain Power.
“Document” and “documentation” should be interpreted as broadly as possible, including all documents which have been created and/or which reside in any type of electronic format. Any document that is not exactly identical to another document for any reason (such as marginal notations or deletions) is considered a separate document.
“Person” or “entity” should be interpreted to denote, unless otherwise specified, any natural person, firm, corporation, association, group, individual or organization of any type whatsoever.
“PSC” or “Commission” means the Wyoming Public Service Commission.
Any request to “identify” or “provide” should be interpreted to mean:
With respect to a natural person, that person’s full name, title, job description, and business and home address. Where the identification pertains to a past period, as to each person identified who is still in your employ, or the employment of the group with which such person is identified in response to any requests, provided, in addition, that person’s title and job description as of the time of such past period. Where the person is no longer in your employ or the employment of the group with which such person is identified in response to any request, provide that person’s affiliate, position, home and business address, if known, or if not known, such person’s last known affiliation, position, home and business address, or portions thereof as may be known.
With respect to an entity other than a natural person, that entity’s name, business, type of entity, present status and present or last known address.
With respect to a document, that document’s title, date, author (and, if different, the signer), addresses, recipients, or other persons who assisted in the preparation, subject matter or general nature, and any amendments thereto, present location and custodian, whether or not such document is in the respondent’s possession, custody or control and whether or not the document is claimed to be privileged. The final version and each draft of each document should be identified and produced separately. Each original and each non-identical copy (bearing marks or notations not found on the original) of each final version and draft of each document should be identified and produced separately.
With respect to a physical facility, the location of the facility, the intended purpose of the facility, the actual use of such facility, the operating dates of the facility, the installation date of the facility, the date utilization of the facility terminated if applicable, and whether the facility is subject to the jurisdiction of the Wyoming Public Service Commission, the Federal Energy Regulatory Commission, or any other regulatory body.
“Communication” should be interpreted to include, but not be limited to, all forms of communication, whether written, printed, oral, pictorial, electronic, or otherwise and by any means or type whatsoever.
“Relating To” or “Related To” means pertaining to, presenting, discussing, commenting on, analyzing, or mentioning in any way.
GENERAL INSTRUCTIONS
Where a request can be answered in whole or in part by reference to the response to a preceding or subsequent request, it is sufficient to so indicate by specifying the response to the preceding or subsequent request by number and specifying whether it is claimed that the response to the preceding or subsequent request is a full or partial response. If the latter, the response to the balance of the request shall be completed.
If various individuals are the authors of different responses to the data requests, please indicate the name of the author and his/her position within the Company. If the author is an expert or a consultant, please provide a current curriculum vitae for each such expert or consultant.
As to any requests consisting of a number of separate subparts, or related parts or portions, a complete response is required to each part or portion with the same effect as if it were propounded as a separate request. Any objection to a request should clearly indicate to which part or portion of the request it is directed.
Responses to requests referring to documents shall include all documents relating to the time period specified in each request or in these instructions, whether prepared before, during or after that period.
If any document related to these data requests is not currently in the Company’s possession but you know or believe such a document exists, please identify and indicate to the best of your ability its present or last known location or custodian.
Individual response of more than one page should be consecutively numbered.
If any document covered by this request is withheld for whatever reason, please furnish a list identifying all withheld documents in the following manner:
the reasons for withholding;
date of the document;
name of each author or preparer;
name of each person who received the document; and
statement of facts constituting the basis for withholding the document.
If you assert that documents, records, or information responsive to any requests have been destroyed and are thus not available, state when and explain why any such document, record or information was destroyed, identify the person directing the destruction and identify all documents relevant to such destruction or explanation. If a claim is made that the destruction occurred pursuant to your document destruction program, identify and produce a copy of the guideline, policy, or company manual describing such document destruction program, and any correspondence or communication relating to the destruction of responsive documents, records or information.
If any of these requests are not answered on the ground that the material or information requested is confidential, privileged, or otherwise immune to discovery, set forth in detail the factual and legal basis which support your decision to withhold production.
Each document or written response shall designate the respective question (and subpart of the question) under which it is being produced.
Each document produced shall be an authentic original document or a true duplicate of an authentic original document.
Each of these requests shall be considered to be continuing and to require supplemental or amended answers as readily as information and knowledge is acquired.
If, in answering a request, you encounter any ambiguity in interpreting either the request or a definition or instruction applicable thereto, please secure a clarification by contacting undersigned counsel as soon as the ambiguity is known.
The term “and” and “or” should be construed either disjunctively or conjunctively whenever appropriate in order to bring within the scope of each request any information or document which might otherwise be considered to be beyond its scope.
The singular form of a word should be interpreted as plural, and the plural form of a word should be interpreted as singular, whenever appropriate in order to bring within the scope of each request.
FIRST SET OF DATA REQUESTS
Please provide a copy of all responses to present and future data requests submitted to Rocky Mountain Power in this proceeding by any and all other parties, including the Wyoming Public Service Commission or its Staff.
Please provide copies of all workpapers which were used to develop or which support Rocky Mountain Power’s Testimony and Exhibits in this docket in native format with all cells and formulae intact. To the extent that such workpapers exist in paper form only, please provide paper copies to the undersigned.
In RMP’s June 16, 2017 Application for Approval of Solicitation Process in Utah Public Service Commission Docket No. 17-035-23, RMP states, “The Company respectfully requests that the Commission issue an order approving the Company’s 2017 Renewable Resources Request for Proposals (“2017R RFP”), seeking up to approximately 1,270 MW of new wind resources capable of interconnecting to, and/or delivering energy and capacity across PacifiCorp’s transmission system in Wyoming” (at page 1, emphasis supplied). Please reconcile this statement with RMP’s statement in its Application in this proceeding (at paragraph 75) that it “respectfully requests that the Commission issue an order granting CPCNs to construct or approval to acquire 860 MW of new Wind Projects in eastern Wyoming…” (emphasis supplied).
Respectfully submitted this 17th day of July, 2017.
HOLLAND & HART LLP
By: Abigail C. Briggerman, #7-5476
Holland & Hart LLP
6380 South Fiddlers Green Circle, Suite 500Greenwood Village, CO 80111
Telephone: (303) [e-mail] FOR WIEC
CERTIFICATE OF SERVICE
I hereby certify that, on this 17th day of July, 2017the WYOMING INDUSTRIAL ENERGY CONSUMERS’ FIRST SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER was served via electronic mail or U.S. Mail, addressed to the following:
Stacy Splittstoesser
Wyoming Regulatory Affairs Manager
Rocky Mountain Power
1807 Capital Avenue, Suite 200A
Cheyenne, WY 82001
[e-mail]
Paul Hickey
Hall & Evans, LLP
P.O. Box 467
Cheyenne, WY 82003-0467
[e-mail]
Wyoming Public Service Commission
2515 Warren Avenue, Suite 300
Cheyenne, WY 82002
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Yvonne R. Hogle
Assistant General Counsel
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, UT 84116
[e-mail]
Katherine McDowell
McDowell Rackner & Gibson PC
419 SW 11th Avenue, Suite 400
Portland, OR 97205
[e-mail]
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
[e-mail]
s/ Adele C. Lee
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